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There are CPT codes for online digital E/M services.

• CPT developed a set of  CPT^® codes for use by physicians, physician assistants and advanced practice nurse practitioners performing brief, online E/M services via a secure platform
• There are also CPT® codes for use by clinicians who do not have E/M within their scope of practice codes 98970—98792
• CMS is requiring verbal consent for communication-based technology services (CBTS)
• This verbal consent is required annually, and encompasses all CBTS, not a consent for each service service or consent for each provision of the service
• These are not considered telehealth services, so do not use POS 02 and modifier 95. Why? they are not on CMS’s list of covered telehealth services, and do not use real-time, interactive audio-visual communication
• Everyday Coding Q&A – Licensed professional counselors and use of 99421–99423

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Watch this short video about CPT code for online digital E/M services. The video also includes HCPCS codes G2010, G2012, G2250, G2251, G2252. There is a link to an article about these HCPCS codes at the end of this article.

CPT® codes for online digital E/M

In the 2020 CPT^® book, CPT deleted code 99444, which was defined as an online E/M service by a physician or other qualified health care professional. CPT^® and added three new time-based codes for online evaluation and treatment, for use by clinicians who have E/M in their scope of practice, and three codes for use by clinicians who do not have E/M in their scope of practice, 98970-98972.

 CPT^® codes for online digital E/M 

99421 Online digital evaluation and management service, for an established patient, for up to 7 days cumulative time during the 7 days; 5-10 minutes

99422            11—20 minutes

99423            21 or more minutes

These codes are for use when E/M services are performed, of a type that would be done face-to-face, through a HIPAA compliant secure platform. These are for patient-initiated communications, and may be billed by clinicians who may independently bill an E/M service. They may not be used for work done by clinical staff or for clinicians who do not have E/M services in their scope of practice.  They are “messaging” codes, not telephone, video or in person services.

Report these services once during a 7-day period, for the cumulative time. According to CPT^®,

“The seven-day period begins with the physician’s or other qualified health care professional’s (QHP) initial, personal review of the patient-generated inquiry. Physician’s or other QHP’s cumulative service time includes review of the initial inquiry, review of patient records or data pertinent to assessment of the patient’s problem, personal physician or other QHP interaction with clinical staff focused on the patient’s problem, development of management plans, including physician  or other QHP generation of prescriptions or ordering of tests, and subsequent communication with the patient through online, telephone, email, or other digitally supported communication, which does not otherwise represent separately reported E/M service.”[1]

Other requirements:

• Verbal consent is required by CMS.
• The patient initiates the service with an inquiry through the portal.
• The service is documented in the medical record.
• If the patient had an E/M service within the last seven days, these codes may not be used for communication related to that problem.
• If the inquiry is about a new problem (from the problem addressed at the E/M service in the past 7 days), these codes may be billed.
• If within seven days of the initiation of the online service a face-to-face E/M service occurs, then the time of the online service or decision-making complexity may be used to select the E/M service, but this service may not be billed.
• These are for established patients, per CPT^®.
• This may not be billed by surgeons during the global period.
• The digital service must be provided via a HIPAA compliant platform, such as an electronic health record portal, secure email or other digital applications.

Additionally:

• These services may only be reported once in a 7-day period.
• Clinical staff time may not be included.
• Don’t double count time with any other separately reported services, such as care management, INR monitoring, remote monitoring. (CPT^® book has a list of codes)

Online services provided by clinicians who may not bill E/M services

CPT ^© codes for clinicians who do not have E/M services in their scope of practice, 98970—98972.  There is an editorial notation after codes 99421, discussed above, that says:

“For online digital E/M services provided by a qualified nonphysician health care professional who may not report the physician or other qualified health care professional E/M services (eg, speech-language pathologists, physical therapists, occupational therapists, social workers, dietitians), see 98970, 98971, 98972).”[2]

CMS, however, said in the 2020 Final Rule that they would not recognize these codes, because they are defined by CPT has “evaluation and management” services, and CMS reserves those words exclusively for physicians, advance practice nurse practitioners and physician assistants.  These codes have a status indicator of invalid in the Medicare fee schedule, and don’t have RVUs assigned to them.

98970 Qualified nonphysician health care professional online digital assessment and management
service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes

98971    11-20 minutes

98972   21 minutes or more

Question: Can a licensed professional counselor use codes 99421–99423 for digital management of a client initiated issue, such as a client-based email inquiry related to their therapy problem?

Answer: No.

These codes appear in the Evaluation and Management section of the CPT® book, and are for use by physicians and other qualified health care professionals. The definition is “online digital evaluation and management service.” Licensed professional counselors do not have E/M services in their scope of practice. If a code is defined as an E/M service, it may only be performed by someone who has E/M in their scope; that is, someone who can perform an office visit or initial hospital service.

There are equivalent codes in the medicine section of the book. In the CPT® 2023 Professional Edition, these start on page 846. The heading is “Qualified Nonphysician Health Care Professional Online Digital Assessment and Management Service.” These codes do not use the words evaluation and management service.  They are 98970, 98971, 98972. Be sure to read the entire section at the start of the codes for the very specific CPT® instructions on their use.

It is confusing, because sometimes both CMS and CPT® use “physician” to include advanced practice nurses and physician assistants.

Virtual communication: HCPCS codes G2010, G2012, G2250, G2251, G2252

Note: G2061, G2062  and G2063 have been deleted, as of Dec. 2020.

[1] CPT Professional Edition, 2023. AMA, Chicago, p. 36.

[2] CPT Professional Edition, AMA, Chicago 2023, page 36.

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